- 5 -
failed to attend various scheduled meetings with respondent’s
representatives and failed timely to produce records.
Respondent’s audit, respondent’s Appeals Office
consideration, and the ultimate settlement of petitioners’ case
in this Court all appear to have been delayed by the haphazard
fashion in which petitioners produced their records.
On the limited record before us in this case, we conclude
that petitioners’ delay in producing records protracted the
administrative and court proceedings within the meaning of
section 7430(b)(3). Petitioners are not entitled to an award of
any litigation costs. See Polyco, Inc. v. Commissioner, 91 T.C.
963, 968 (1988).
To reflect the foregoing,
An appropriate order and
decision will be entered.
Page: Previous 1 2 3 4 5
Last modified: May 25, 2011